D. Arizona cuts ERISA benefits fee award 15.7%, including for block billing

What happened

The fee applicant sought $30,400 in ERISA fees. The court awarded $25,625.30, a reduction of $4,774.70 or 15.7%. It cut by 40% the time spent on a reply supporting a motion that repeated the original arguments, over 20 hours, and cut by 40% several entries that listed more than one task without showing how long each took. Entries that duplicated efforts or lacked enough description, such as emails and calls with someone named Steve Strang, were not compensated at all.

What the court said

several other entries contain more than one task without indicating how long those separate tasks took. Those entries will be reduced by 40%.

Other entries either duplicate efforts or lack any description that allows the Court to determine if it was reasonable, such as elusive emails and calls with someone named “Steve Strang” ... Those entries will not be compensated at all.

The court also reduced the award for: excessive hours, duplicative staffing.

Why it matters

The ruling shows that a fee petition can lose value even when the overall request is modest. Courts will reduce entries that combine tasks without separating the time, and will deny compensation entirely for entries too vague to assess or that repeat work already billed.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the D. Arizona approves and attorney fee motions in Arizona federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.